14-4-3286 Foreign Producer Questionnaire

OMB No. 3117-0016/USITC No. 14-4-3286; Expiration Date: 6/30/2014
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
POLYETHYLENE TEREPHTHALATE FILM, SHEET, AND STRIP FROM BRAZIL, CHINA,
AND UNITED ARAB EMIRATES

This questionnaire must be received by the Commission by no later than September 18, 2014
See the Instruction Booklet for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its review of the antidumping duty orders concerning polyethylene terephthalate film, sheet, and strip
(PET film) from Brazil, China, and the United Arab Emirates (“the UAE”) (inv. Nos. 701-TA-1131-1132, and 1134
(Review)). The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title
VII.

Name of firm
Address
World Wide Web address
Has your firm produced or exported PET film (as defined in the instruction booklet) at any time since January 1,
2008?

NO
YES

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
(Read the instruction booklet carefully, complete all parts of the questionnaire, and return the entire
questionnaire to the Commission so as to be received by the date indicated above)

Data reported in this questionnaire relate to (Check one):
Brazil

China

United Arab Emirates

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking
on the following link: https://dropbox.usitc.gov/oinv/. (use the following PIN: PETBCU)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my knowledge
and belief and understand that the information submitted is subject to audit and verification by the Commission.
By means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings or reviews
conducted by the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout this proceeding may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of this proceeding or related proceedings for which this information is submitted, or in internal audits and
proceedings relating to the programs and operations of the Commission pursuant to 5 U.S.C. Appendix 3. I understand that all
contract personnel will sign non-disclosure agreements.

Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Email address
Fax:

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 2
PART I.--GENERAL INFORMATION
The questions in this questionnaire have been reviewed with market participants to ensure that issues of
concern are adequately addressed and that data requests are sufficient, meaningful, and as limited as
possible. Public reporting burden for this questionnaire is estimated to average 30 hours per response,
including the time for reviewing instructions, searching existing data sources, gathering the data needed,
and completing and reviewing the questionnaire. Send comments regarding the accuracy of this burden
estimate or any other aspect of this collection of information, including suggestions for reducing the
burden, to the Office of Investigations, U.S. International Trade Commission, 500 E Street, SW,
Washington, DC 20436.
I-1a.

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of preparing the reply to this questionnaire and completing the form.
Hours

Dollars

I-1b.

OMB feedback.--We are interested in any comments you may have for improving this
questionnaire in general or the clarity of specific questions. Please attach such comments to your
firm’s response or send them to the above address.

I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire (see page 3 of the instruction booklet for reporting guidelines). If your firm is
publicly traded, please specify the stock exchange and trading symbol.

I-3.

U.S. importers.--Please provide the names, contacts, email addresses, and telephone numbers of
the FIVE largest U.S. importers of your firm’s PET film in 2013.

No.

1
2
3
4
5

Importer’s name

Contact person

Email address

Area
code and
telephone
number

Share of
your firm’s
2013
exports
(%)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 3
PART I.--GENERAL INFORMATION--Continued
I-4.

U.S. production.--Does your firm or any related firm produce, have the capability to produce, or
have any plans to produce PET film in the United States or other countries?
No

I-5.

U.S. importation.--Does your firm or any related firm import or have any plans to import PET
film into the United States?
No

I-6.

Yes--Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire
(contact Michael Haberstroh ([email protected]) for
copies of that questionnaire).

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire (contact Michael Haberstroh
([email protected]) for copies of that questionnaire).

Business plan.--In Parts II and III of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected future market conditions for PET film?
No

Yes--Please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 4
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Michael Haberstroh (202205-3390, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted in
part II.
Name
Title
Email
Telephone
Fax

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of PET film since January 1, 2008.
(check as many as appropriate)
plant openings ..............................

plant closings................................

relocations ....................................

expansions ....................................

acquisitions...................................

consolidations...............................

prolonged shutdowns or
production curtailments................
revised labor agreements ..............

other (e.g., technology) ................

(please describe)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 5
PART II.--TRADE AND RELATED INFORMATION--Continued
II-3.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of PET film in the
future?
No

II-4.

Yes–Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce PET film (in 1,000 pounds) for 2014 and 2015.

Anticipated changes in operations in the event the orders are revoked.--Would your firm
anticipate any changes in the character of its operations or organization (as noted above) relating
to the production of PET film in the future if the antidumping duty orders on PET film from
Brazil, China, and/or the UAE were to be revoked?
No

II-5a.

Yes–Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce PET film (in 1,000 pounds) for 2014 and 2015.

Production and capacity.-- Please report your firm’s production of PET film, production of
products made on the same equipment and machinery used to produce PET film, and the
combined production capacity on this shared equipment and machinery in the periods indicated.
(Quantity in 1,000 pounds)
Calendar Year
Item

2008

2009

2010

January-June

2011

2012

2013

2013

2014

Overall Production Capacity
Production of:
1
Subject merchandise
Other products

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Total production
1

Data on production of PET film will be populated from information entered into the main trade grid below
(question II-12).
2
Please describe these products.

.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 6
PART II.--TRADE AND RELATED INFORMATION--Continued

II-5b.

Operating parameters.--The production capacity (see definitions in instruction booklet) reported in
II-5a is based on operating
hours per week,
weeks per year.

II-5c.

Capacity calculation.--Please describe the methodology used to calculate overall production capacity
reported in II-5a, and explain any changes in reported capacity.

II-5d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-5e.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between PET film and other products
using the same equipment and/or labor?
No

(ii)

Yes-- (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:

Please describe the factors that affect your firm’s ability to shift production capacity between
products (e.g., time, cost, relative price change, etc.), and the degree to which these factors
enhance or constrain such shifts.

II-6.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of PET film?
percent

II-7.

Inventories in the United States.--Has your firm, since January 1, 2008, maintained any
inventories of PET film in the United States (not including inventories held by firms identified in
question I-3)?
No

Yes--Report the quantity of such end-of-period inventories below.
(Quantity in 1,000 pounds)
Item

Inventory

Calendar Year
2008

2009

2010

2011

January - June
2012

2013

2013

2014

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 7
PART II.--TRADE AND RELATED INFORMATION--Continued
II-8.

Barriers.-(a)

Are your firm’s exports of PET film subject to tariff or non-tariff barriers to trade (for
example, antidumping or countervailing duty findings or remedies, tariffs, quotas, or
regulatory barriers) in any countries other than the United States?
No

(b)

Are your firm’s exports of PET film subject to current proceedings in any countries other
than the United States that might result in tariff or non-tariff barriers to trade?
No

II-9.

Yes--List the products(s), country(ies), the year each such barrier was
imposed, and the type of barrier.

Yes--List the products(s), country(ies), and type of proceeding.

Other export markets.--Identify export markets (other than the United States) that your firm has
developed or where it has increased its sales of PET film since January 1, 2008. Please identify
and discuss below.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 8
PART II.--TRADE AND RELATED INFORMATION--Continued
II-10.

Significance of the antidumping duty orders.--Describe the significance of the existing
antidumping duty orders covering imports of PET film from Brazil, China, and/or the UAE in
terms of their effect on your firm’s production capacity, production, home market shipments,
exports to the United States and other markets, and inventories. You may wish to compare your
firm’s operations before and after the imposition of the orders.

II-11.

Anticipated changes if order revoked.--Would your firm anticipate any changes in its
production capacity, production, home market shipments, exports to the United States and other
markets, or inventories relating to the production of PET film in the future if the antidumping
duty orders on PET film from Brazil, China, and/or the UAE were to be revoked?
No

Yes–Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation for any trends or
projections you may provide.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 9
PART II.--TRADE AND RELATED INFORMATION--Continued
II-12.

Trade data.-- Report production capacity, production, shipments, and inventories of PET film
produced by your firm in Brazil, China, or the UAE during the specified periods. (See
definitions in the instruction booklet.) Do not submit data on multiple countries combined. The
establishments reported here should all be located in the country of the firm’s address reported on
the certification page. Multinational companies with production in multiple subject countries
should submit separate foreign producer questionnaire responses for each subject country.

Note: With regard to PET film from BRAZIL, products produced and sold by Terphane under
product codes 10.21/32, 10.21/40, 10.21/48, 10.21/92, 10.81/48, 10.91/48, and 10.96/48 (copolymer
surface films) are not in the scope of the order on PET film from BRAZIL. Hence, data relative

to these product codes should not be included in data reported for Brazil.
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
Calendar year
Item

2008

2009

2010

2011

2012

2013

1

Average production capacity (A)
Beginning-of-period inventories (B)
2

Production (C)
Home market shipments:
Internal consumption/transfers
quantity (D)
Commercial shipments
quantity (E)
value (F)
Export shipments:
3
to the United States:
quantity (G)
value (H)
to the European Union:
quantity (I)

4

value (J)
5

to Asia:
quantity (K)
value (L)
6

to all other markets:
quantity (M)
value (N)

Total exports (quantity) (O)
Total shipments (quantity) (P)
End-of-period inventories (Q)
1

The production capacity (see definitions in instruction booklet) reported is based on operating
hours per week,
weeks per year. Please describe the methodology used to calculate production capacity, and explain any changes in
reported capacity.
2

Please estimate the percentage of total production of PET film accounted for by your firm’s production in 2013:
percent
3
Please estimate the percentage of total exports to the United States of PET film accounted for by your firm’s exports in
2013:
percent
4
Identify your firm’s principal European Union export markets:
.
5
Identify your firm’s principal Asian export markets:
.
6
Identify your firm’s principal other export markets:
.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 10
PART II.--TRADE AND RELATED INFORMATION--Continued
II-12.

Trade data.—Continued
Report production capacity, production, shipments, and inventories of PET film produced by your
firm in Brazil, China, or the UAE during the specified interim periods.

Note: With regard to PET film from BRAZIL, products produced and sold by Terphane under
product codes 10.21/32, 10.21/40, 10.21/48, 10.21/92, 10.81/48, 10.91/48, and 10.96/48 (copolymer
surface films) are not in the scope of the order on PET film from BRAZIL. Hence, data relative

to these product codes should not be included in data reported for Brazil.
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
Item

January – June 2013

January – June 2014

1

Average production capacity (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:
Internal consumption/transfers
quantity (D)
Commercial shipments
quantity (E)
value (F)
Export shipments:
to the United States:
quantity (G)
value (H)
to the European Union:
quantity (I)
value (J)
to Asia:
quantity (K)
value (L)
to all other markets:
quantity (M)
value (N)
Total exports (quantity) (O)
Total shipments (quantity) (P)
End-of-period inventories (Q)
1

The production capacity (see definitions in instruction booklet) reported is based on operating
hours per week,
weeks per year. Please describe the methodology used to calculate production capacity, and explain any changes in
reported capacity.

.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 11
PART II.--TRADE AND RELATED INFORMATION--Continued
II-13.

Reconciliation of trade data.-(a)

Generally, the data reported for the end-of-period inventories (i.e., line Q) should be
equal to the beginning-of-period inventories (i.e., line B), plus production (i.e., line C),
less total shipments (i.e., lines D, E, G, I, K, M). Please ensure that any differences are
not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for the differences (e.g., theft, loss,
damage, record systems issues, etc.) If the calculated fields below return values other
than zero (i.e., “0”), please correct any data errors in question II-12 or explain below: .
Calendar Year

Reconciliation test
B+C–D–E–G–I–K–M
should = zero ("0"), or if not
equaling to zero, the reason
explained below

(b)

2009

0

2010

0

January-June

2011

0

2012

0

2013

0

2013

0

2014

0

Please note that the quantities reported for end-of-period inventories should equal the
beginning-of-period inventories reported in the subsequent calendar year (i.e., line Q of
year 2008 should equal line B of year 2009). Do these data reconcile for each adjacent
calendar year?
Yes.

II-14.

2008

No--Please explain.

Transfers to related firms.--If your firm reported transfers to related firms in question II-12,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

0

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 12
PART III.--MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected])).
III-1.

Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact the individual regarding the confidential information submitted in
part III.
Name
Title
Email
Telephone
Fax

III-2.

Contract versus spot.--Approximately what share of your firm’s sales of PET film to U.S.
customers in 2013 was on a (1) long-term contract basis, (2) short-term contract basis, and
(3) spot sales basis?

Long-term contracts
(multiple deliveries for
more than 12 months)
Share of your 2013
sales

III-3.

Type of sale
Short-term contracts
(multiple deliveries up
to and including 12
months)

%

Spot sales
(for a single
delivery)

%

%

Total
(should sum
to 100%)
0.0

Please fill out the table with respect to provisions of your firm’s typical sales contracts with U.S.
customers for PET film (or check “not applicable” if your firm does not sell on a long term and/or
short term contract basis).

Typical sales contract
provisions

Item

Average contract duration

Number of days

Price renegotiation (during the
contract period)

Yes
No
Quantity

Fixed quantity and/or price

Price
Both

Meet or release provision
Not applicable

Yes
No

Short term contracts

Long term contracts

(multiple deliveries up to
and including 12 months)

(multiple deliveries for more
than 12 months)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 13
PART III.--MARKET FACTORS--Continued
III-4.

Lead times.--What is the typical lead time for PET film to U.S. customers between a customer’s
order and the date of delivery for your firm’s sales of PET film?
Share of
2013 sales

Source
From inventory

%

Produced to order

%

Total (should
sum to 100%)

III-5.

(a)

To what extent have changes in the prices of raw materials affected your firm’s selling
prices for PET film since January 1, 2008?

(b)

Do you anticipate changes in your firm’s raw material costs in the foreseeable future?
Yes

If yes, please explain.

Changes in factors affecting supply.--Have any changes occurred in any other factors affecting
supply (e.g., changes in availability or prices of energy or labor; transportation conditions;
production capacity and/or methods of production; technology; export markets; or alternative
production opportunities) that affected the availability of Brazil, China, and the UAE -produced
PET film in the U.S. market since January 1, 2008?
No

III-7.

%

Raw materials.—

No

III-6.

0.0

Lead time (days)

Yes

If yes, please describe.

Availability of SUBJECT import supply.-- Do you anticipate any changes in terms of the
availability of Brazil, China, and/or the UAE-produced PET film in the U.S. market in the future?
If you anticipate changes in supply, please identify the
No
changes, including the time period and the impact of such
Increase change Decrease changes on shipment volumes and prices.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 14
PART III.--MARKET FACTORS--Continued
III-8.

Product shifting.--Describe how easily your firm can shift its sales of PET film between the U.S.
market and alternative country markets. In your discussion, please describe any contracts, other
sales arrangements, or other constraints (including any third-country trade barriers such as tariffs,
quotas, or other non-tariff barriers) that would prevent or retard your firm from shifting PET film
between the U.S. and alternative country markets within a 12-month period.

III-9.

Product range.--Is the product range, product mix, or marketing of PET film in your firm’s
home market different from that of PET film for export to the United States or to third-country
markets?
No

Yes

If yes, please explain.

III-10. Product changes.--Have there been any significant changes in the product range, product mix, or
marketing of PET film in your firm’s home market, for export to the United States, or for export
to third-country markets since January 1, 2008? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2008
Anticipated
changes

Explain

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 15
PART III.--MARKET FACTORS--Continued
III-11. Substitutes.— Can other products be substituted for PET film?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

Have changes in the price of this substitute
affected the price for PET film?
No Yes

Explanation

1.
2.
3.

III-12. Changes in substitutes.-- Have there been any changes in the number or types of products that
can be substituted for PET film since January 1, 2008? Do you anticipate any future changes?
Changes in
substitutes

No Yes

Explain

Changes since
January 1, 2008
Anticipated
changes

III-13. Interchangeability.--Is the PET film produced by your firm and sold in its home market
interchangeable (i.e., can be used in the same applications) with your firm’s PET film sold to the
United States and/or to third-country markets?
Yes

No

If no, identify the market(s) and any differences in the products.

III-14. End uses.--Describe the end uses of the PET film that your firm manufactures and sell to your
firm’s home market. If these end uses differ from those of the PET film your firm sells to the
U.S. market or to third-country markets, explain.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
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PART III.--MARKET FACTORS--Continued
III-15. Changes in end uses.-- Have there been any changes in the end uses of PET film since January 1,
2008? Do you anticipate any future changes?
Changes in end
uses

No

Yes

Explain

Changes since
January 1, 2008
Anticipated
changes

III-16. Demand trends.-- Indicate how demand in the following markets for PET film has changed since
January 1, 2008, and how you anticipate demand will change in the future. Explain any trends
and describe the principal factors that have affected, and that you anticipate will affect, these
changes in demand.
Your
firm’s
market

Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explanation and factors

Demand since January 1, 2008
Home
market
United
States
Other
markets
Anticipated future demand
Home
market
United
States
Other
markets

III-17. Price differences.--Please compare market prices of PET film in your firm’s home market, the
United States, and third-country markets.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire - PET Film from Brazil, China, and the UAE (Review)
Page 17
PART III.--MARKET FACTORS--Continued
III-18. International transportation.—
(a) Who typically arranges international transportation for your firm’s exports?
Exporter

Importer

(b) If your firm typically arranges international transportation, for 2013, report or estimate the
average cost to ship typical volumes of PET film to the United States.
dollars per short ton
III-19. Description of home market.--Describe briefly your firm’s home market for PET film, including
the number of, and competition between, producers.

III-20. Import competition.--Does your firm face competition from imports of PET film in your firm’s
home market?

No

Yes

If yes, please identify the country sources of any imports of PET film into
your firm’s home market.

III-21. Market studies.--Please provide as a separate attachment to this request any studies, surveys, etc.
that you are aware of that quantify and/or otherwise discuss PET film supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of the
other major producing/consuming countries, including Brazil, China, and the UAE, and (3) the
world as a whole. Of particular interest is such data from January 1, 2008 to the present and
forecasts for the future.